Conflicts of Interest Disclosure Procedures

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Abstract

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Disclosure Procedures

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1. Identification of Potential Conflict

• Initial Identification: Any Endaoment team member who suspects they may have a conflict of interest should initially assess the situation against the organization’s conflict of interest policy.
• Consultation: If uncertain, the team member should consult with their supervisor for guidance.

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2. Formal Disclosure

• Disclosure Form: The individual must complete a disclosure Form. This form will be available on Endaoment’s internal portal and in hard copy from the HR department.
• Detailed Description: The form should include a comprehensive description of the potential conflict, including the nature of the personal interest and its overlap with Endaoment’s activities.

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3. Submission of Disclosure

• Direct Submission: The completed form should be submitted directly to the designated ethics mailbox.
• Confidential Handling: All disclosures will be treated with the utmost confidentiality, and in line with our anti-retaliation practices.

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Review and Decision-Making Process

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1. Initial Review

• Assessment: The designated officer will conduct an initial review of the disclosure to determine the extent of the conflict.
• Consultation with Senior Management: If necessary, the officer may consult with senior management, the board, or legal advisors for additional perspective.

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2. Decision Making

• Ethics Committee Review: Complex or significant conflicts will be escalated to the Ethics Committee for a detailed review.
• Decision and Recommendations: The Ethics Committee will decide on the appropriate action, which may range from no action needed to adjustments in duties or decision-making roles.

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3. Communication of Decision

• Feedback to the Individual: The individual who disclosed the conflict will be informed of the decision and any necessary actions they need to take.
• Ongoing Monitoring: The situation will be monitored to ensure that the conflict is managed effectively.

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Record Keeping and Transparency

• Documentation: All disclosures and actions taken will be documented and securely stored.
• Annual Review: The officer will conduct an annual review of all conflict of interest disclosures to identify any patterns or systemic issues.

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Training and Support

• Regular Training: Endaoment will provide periodic training to all staff on conflict of interest identification and disclosure procedures.
• Support and Guidance: Ongoing support and guidance will be available to help staff navigate and adhere to these procedures.

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Reporting Violations

• Whistle-blower Protection: Endaoment provides a secure and confidential channel for reporting any violations or concerns regarding conflicts of interest, with protection against retaliation.

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Continuous Improvement

• Policy Review and Updates: The conflict of interest policy and disclosure procedures will be reviewed regularly and updated as necessary to reflect changes in the organization and regulatory environment.